Case Digest (G.R. No. 192571)
Facts:
Abbott Laboratories, Philippines, et al. v. Pearlie Ann F. Alcaraz, G.R. No. 192571, July 23, 2013, the Supreme Court En Banc, Perlas‑Bernabe, J., writing for the Court. Petitioners are Abbott Laboratories, Philippines and several corporate officers (Bernardo, Feist, Misa, Terrible, Almazar and Walsh); respondent is Pearlie Ann F. Alcaraz, former Regulatory Affairs Manager employed under a probationary contract.In 2004–2005 Abbott recruited for a Regulatory Affairs Manager post; Alcaraz applied, received an offer stating probationary status, and signed a probationary employment contract effective February 15, 2005 to August 14, 2005. Abbott gave Alcaraz job descriptions, an organizational chart, copies of its Code of Conduct and Performance Modules, and conducted a pre‑employment orientation; she began supervising Hospira ALSU staff and encountered disciplinary and performance issues with subordinates and tensions with a supervising manager, Kelly Walsh.
On May 19, 2005 Abbott delivered a termination letter stating Alcaraz failed to meet time‑management, people‑management and case‑processing standards, and instructed her not to report for work; Alcaraz filed a complaint for illegal dismissal and damages. The Labor Arbiter (LA) dismissed her complaint in a Decision dated March 30, 2006, finding Abbott had informed her of standards and terminated validly. The National Labor Relations Commission (NLRC) reversed on September 15, 2006, declaring the dismissal illegal, ordering reinstatement and awarding backwages, moral and exemplary damages, and attorney’s fees; the NLRC denied reconsideration on July 31, 2007.
Abbott filed a certiorari petition with the Court of Appeals (CA) (CA‑G.R. SP No. 101045). The CA, in a decision dated December 10, 2009, affirmed the NLRC, holding Abbott had not informed Alcaraz of the reasonable standards and that the NLRC did not commit grave abuse of discretion; reconsideration was denied June 9, 2010. Abbott also sought review of writ‑of‑execution matters in a separate CA petition (CA‑G.R. SP No. 111318), which was denied and later became final. Abbott then filed a Petition for Review on Certiorari with this Court (Rule 45), assailing the CA decision. The issues included allegations of forum sho...(Subscriber-Only)
Issues:
- Did petitioners engage in forum shopping or violate the certification requirement under Section 5, Rule 7 of the Rules of Court?
- Was Alcaraz sufficiently informed of the reasonable standards that would govern her regularization at the time of engagement?
- Was Alcaraz validly terminated from employment under applicable Labor Code provisions and implementing rules?
- Are the individual petitioners personally liable fo...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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